State v. Echols

Echols (defendant) stole a purse from inside a victim's home while she was outside taking out her trash; when she came back in, found her purse missing, and rushed back outside to scream for help and look for Echols, she fell and fractured her hip. The State (plaintiff) charged Echols with aggravated robbery, which required proof he caused serious bodily injury, and the jury convicted him; he appealed, arguing the victim's own actions in falling were the actual proximate cause of her injury, not his theft.